Minnesota Medicaid Licensing vs Payment Structural Gap

Author: Minnesota Medicaid Transparency Project | Last updated: March 27, 2026

DHS controls 245D licensing but MCOs bear 86% of payment risk. The structural gap between licensing and payment enables provider proliferation.

Part of the Minnesota Medicaid Transparency Project — an independent, data-driven investigation of $23 billion in annual Medicaid spending across 87 counties.